AccountingLink

    Comment Letters

    21 July 2016

    Comment Letter - Regulation S-K concept release
    In our comment letter, we recommend the SEC move to a disclosure framework that articulates clear disclosure objectives and allows registrants to more effectively communicate material information to investors. We ask the SEC to consider enhancements to various business and financial disclosures, including those related to the description of the business, risk factors and management’s discussion and analysis. We also suggest that the SEC explore ways to improve the presentation and delivery of information through a company profile approach.

    30 June 2016

    Comment letter - FASB proposal on goodwill impairment
    In our comment letter, we supported the FASB’s objective of simplifying the accounting for goodwill impairment and said we believe the proposed amendments would reduce the complexity of applying the goodwill impairment assessment. However, we recommended that the Board consider certain changes in the proposal. We also said that we believe the Board should continue to simplify the subsequent accounting for goodwill in the next phase of its project and that any future amendments should be practical in nature.

    29 June 2016

    Comment Letter - FASB proposal on technical corrections and improvements
    In our comment letter on the Proposed Accounting Standards Update, Technical Corrections and Improvements, we agree that for the most part, the proposed changes would clarify the Accounting Standards Codification, correct unintended application of guidance or make minor improvements to the Codification that would not be expected to have a significant effect on current accounting practice or create a significant administrative cost for most entities. However, we express concerns about certain of the proposed amendments

    29 June 2016

    Comment letter - FASB proposal on technical corrections and improvements to its revenue standard
    In our comment letter, we support the FASB’s proposal to address feedback received from stakeholders and to make other improvements to its new revenue standard. Overall, we believe that the proposed amendments would address many of the concerns raised by constituents, provide additional clarity and improve consistency in application. We also recommend additional clarifications.

    25 April 2016

    Comment letter - FASB proposal on changes to disclosure requirements for defined benefit plans
    In our comment letter, we support the proposed elimination of certain disclosure requirements but have concerns about how entities would apply the materiality assessments under the FASB’s proposed ASU on materiality. We also are concerned that certain proposed disclosure requirements, together with current ones required by ASC 715, Compensation – Retirement Benefits, could further reduce disclosure effectiveness.

    25 April 2016

    Comment letter - FASB proposal on changes to the reporting of net periodic pension cost and net periodic postretirement benefit cost
    In our comment letter, we said we agree that only the service cost component of net periodic pension cost and net periodic postretirement benefit cost should be eligible for capitalization in assets. We also believe that the prior service cost or credit component should be presented in the same financial statement line item as the current service cost component within operating income. However, we have concerns about the proposed amendment that would require entities to present the other components of net periodic pension cost and net periodic postretirement benefit cost outside a measure of operations.

    30 March 2016

    Comment Letter - SEC’s proposal to regulate funds’ use of derivatives
    In our comment letter, we say closed-end funds that rely on the proposed exemption for derivatives and financial commitment transactions should not be required to reflect these instruments as senior securities in their senior securities table disclosures or as components of the calculations from which these disclosures are derived, and we recommend that the SEC provide guidance on this point. We also recommend that the SEC consider eliminating the requirement that the senior securities table be audited. Finally, we recommend that, if the SEC decides not to rescind the audit requirement, the SEC should clarify that an auditor’s responsibility regarding the senior securities table does not extend to evaluating a closed-end fund’s compliance with the provisions of proposed Rule 18f-4.

    29 February 2016

    Comment letter - FASB proposal on fair value measurement disclosures
    In our comment letter, we support both the FASB’s objective to improve the effectiveness of disclosures and the proposed elimination of certain fair value disclosure requirements, including the relief that would be provided to private companies. However, we highlight the cost of implementing some of the additional requirements the FASB proposed, including the disclosures of the amount of changes in unrealized gains and losses for recurring Level 1 and Level 2 measurements disaggregated by class.

    22 February 2016

    Comment Letter - SEC rules implementing provisions of the FAST Act
    In our comment letter, we suggested that the SEC allow forward incorporation by reference of Exchange Act reports into Form S-1 by all registrants, not just smaller reporting companies as provided by the interim final rules adopted by the SEC in January. We also recommended that the SEC remove the Form S-1 and F-1 requirement for a registrant to be “seasoned” (i.e., file its first annual report) to be eligible to incorporate by reference. In addition, we suggested that the SEC allow an EGC to omit interim financial statements (and related pro forma information, MD&A and selected financial data) from its initial IPO filing or submission if they will not be required at effectiveness.

    10 February 2016

    Comment Letter - FASB proposal on disclosures of government assistance
    In our comment letter, we supported the FASB’s objective of improving the reporting and disclosure of certain government assistance arrangements, but we did not agree that the approach taken by the Board would meet that objective. We believe that the FASB should first develop recognition and measurement guidance for government assistance arrangements and then consider disclosure requirements for arrangements within the scope of that guidance. If the Board believes that additional disclosures should be required for arrangements accounted for under other topics in the Accounting Standards Codification, we believe that the Board should amend the disclosure requirements in those topics to specifically address those matters.

    21 January 2016

    Comment Letter - FASB proposal on the definition of a business
    In our comment letter, we supported the FASB’s objective of helping entities evaluate whether transactions should be accounted for as acquisitions (or disposals) of assets or businesses and said we believe the proposed amendments would simplify the evaluation. However, we recommended that the Board consider amending certain language and clarifying some of the examples in the proposal.

    14 January 2016

    Comment Letter - SEC’s fund liquidity and swing pricing proposal
    In our comment letter, we recommend that the SEC clarify how mutual funds that would be allowed to use swing pricing (i.e., adjust net asset value per share (NAV) for costs associated with satisfying requests for shareholder purchases and redemptions that exceed certain thresholds) would present NAV on the balance sheet and certain financial highlights and how they would adjust NAV for trade date activity, among other things. We also express our view that auditors should not be responsible for assessing the reasonableness of a fund’s swing pricing policies and procedures and recommend that the SEC clarify that point in any adopting release.

    23 December 2015

    Comment Letter - Amendments to conceptual framework for financial reporting, chapter 3: qualitative characteristics of useful financial information
    In our comment letters, we continue to support the objective of the FASB in its disclosure framework project to improve disclosure effectiveness in the notes to the financial statements. We supported the FASB’s proposal to align its definition of materiality in the Conceptual Framework with that of the SEC and the PCAOB. However, we have concerns that the proposed evaluation of materiality of omitted disclosures is not sufficiently clear to be applied consistently by preparers, auditors and regulators.

    23 December 2015

    Comment Letter - Assessing whether disclosures are material
    In our comment letter, we continue to support the objective of the FASB in its disclosure framework project to improve disclosure effectiveness in the notes to the financial statements. We supported the FASB’s proposal to align its definition of materiality in the Conceptual Framework with that of the SEC and the PCAOB. However, we are concerned that focusing on materiality solely as a legal concept could lead to materiality decisions becoming legal determinations, when in fact they should be accounting determinations.

    20 November 2015

    Comment Letter - Regulation S-X requirements for other entities
    In our comment letter, we responded to the SEC’s request for feedback on requirements that registrants disclose information about other entities (e.g., acquired businesses, equity method investees and subsidiary issuers and guarantors) and said the rules are complex and require disclosures that are not as useful as they could be. We recommended simplifying the significance tests, enhancing pro forma financial information and expanding the use of abbreviated financial statements and summarized financial information to reduce the compliance costs while still providing investors with material information. We encourage others to submit comments and believe the SEC will accept and consider them after the official comment period closes on 30 November 2015.

    20 November 2015

    Comment letter - Regulation S-X requirements for registrant’s financial statements
    In our comment letter, we encouraged the SEC to streamline annual and quarterly reporting requirements, eliminate inconsistencies between the disclosure requirements of the Securities Act of 1933 and Exchange Act of 1934 and coordinate with the FASB to eliminate duplicative disclosure requirements.

    16 November 2015

    Comment Letter - FASB proposal on effective date and transition guidance for existing PCC alternatives
    In our comment letter, we said we continue to support providing relief to private companies under US GAAP and believe the proposal would meet that objective by allowing private companies to forgo a preferability assessment the first time they adopt an existing Private Company Council (PCC) alternative. However, we do not believe it is necessary to add a provision indicating that private companies can forgo a preferability assessment the first time they elect to apply the simplified hedge accounting approach. We also support extending the transition guidance in the PCC alternatives indefinitely.

    16 November 2015

    Comment Letter - FASB proposal on narrow scope improvements and practical expedients for its revenue standard
    In our comment letter, we supported the FASB’s proposal to clarify the guidance in its new revenue standard on collectibility, presentation of sales and similar taxes, noncash consideration and transition. Overall, we believe that the proposed clarifications would improve consistency and, in many cases, provide a practical approach to applying the new standard. We also recommended additional clarifications.

    15 October 2015

    Comment Letter - FASB proposal to clarify the principal versus agent guidance in the new revenue standard
    In our comment letter, we supported the FASB’s proposal to clarify the principal versus agent guidance in its new revenue standard and further supported the decision by the FASB and the IASB to propose converged amendments to this guidance. Overall, we believe that the proposed amendments would enhance the operability of the standard and result in more consistent application across entities, although significant judgment would still be required. We also recommended additional clarifications.

    29 September 2015

    Comment Letter - AICPA proposed statement on forming an opinion and reporting on financial statements
    In our comment letter, we support the proposed Statement on Auditing Standards. We believe the amendments will improve consistency in reporting when an audit is conducted in accordance with both GAAS and the standards of the PCAOB and the audit is not within the jurisdiction of the PCAOB.

    28 September 2015

    Comment Letter - PCAOB concept release on audit quality indicators
    In our comment letter, we supported the PCAOB’s efforts to develop relevant audit quality indicators (AQIs) that could provide stakeholders, such as audit committees, investors, audit firms and regulators, with additional perspective on matters that affect audit quality. We believe context is critical to understanding and interpreting AQIs to avoid misperceptions that might lead to unintended consequences. Therefore, we believe the PCAOB should allow audit firms and audit committees to continue to voluntarily develop AQIs and should not require a particular set of AQIs and a disclosure approach.

    15 September 2015

    Comment Letter - SEC proposed clawback rule
    In our comment letter, we asked the SEC to consider clarifying the scope of restatements that would trigger a clawback of excess incentive-based compensation to executives, as well as when the three-year look-back period would be triggered. We also suggested that the SEC not require an issuer to disclose how it arrived at a conclusion that errors were immaterial (and thus did not trigger a clawback). Finally, we asked the SEC to provide guidance on applying the clawback provisions when a restatement does not affect the stock price.

    8 September 2015

    Comment Letter - SEC concept release on audit committee disclosures
    In our comment letter, we said that allowing audit committees to respond to investor needs and the evolving corporate governance landscape is preferable to developing prescriptive rules at this time. We included results from our research showing a steady increase in the depth and scope of voluntary audit committee-related disclosures by Fortune 100 companies since the 2012 proxy season. We suggested that if the SEC decides to take further action, it should clarify the purpose and objectives of the audit committee report in a way that is broad and principles-based. We also discussed fundamental disclosure objectives and identified opportunities to strengthen audit committee disclosures under current rules.

    31 August 2015

    Comment Letter - PCAOB proposal on disclosure of the engagement partner and certain other participants in audits
    In our comment letter, we said we believe the PCAOB’s proposed Form AP is a much better approach than requiring disclosure in the audit report. While we continue to believe disclosures about the audit should focus on firm-wide accountability and not on specific individuals, we appreciate the efforts the PCAOB has made to take into account the legal and practical challenges that would be created by requiring audit firms to identify the engagement partner and other audit participants in the auditor’s report.

    19 August 2015

    Comment Letter - FASB proposal on presentation of not-for-profit financial statements
    In our comment letter, we supported the FASB’s objective of improving financial statement presentation by not-for-profit entities (NFPs) provided any changes are simple and straightforward and scalable to all affected entities. We supported many of the proposed amendments that address issues that are unique to NFPs such as the proposed changes to the classification of net assets and certain amendments that would eliminate diversity in practice. However, we did not support the development of significantly different financial reporting models for NFPs and business enterprises, especially in areas where the objectives of financial reporting do not differ between these types of entities (e.g., reporting measures of operations, reporting of cash flows).

    14 August 2015

    Comment Letter - FASB proposal to simplify share-based payment accounting
    In our comment letter, we said we believe that the proposal would reduce costs and complexity by allowing all entities to elect to account for forfeitures of share-based payments as they occur and by providing two practical expedients for nonpublic entities. We support increasing the threshold for the exception to liability classification related to shares withheld for employees’ taxes and propose that the exception be extended to partnerships and other pass-through entities that do not have a withholding obligation. While we agree with the FASB’s proposal to eliminate the accounting for the pool of excess tax benefits, we believe that excess tax benefits and tax deficiencies should be recorded in additional paid-in capital, rather than in the income statement.

    10 August 2015

    Comment Letter - Investment company reporting modernization
    In our comment letter, we supported the Commission’s efforts to improve the transparency and comparability of investment company financial statements for their intended users. However, we have concerns about whether some of the proposed amendments to Regulation S-X, such as those related to disclosures of illiquid securities, the tax basis of derivatives, the notional amounts and value for options and futures contracts, and securities lending activities, would enhance consistency and transparency of financial reporting and whether they achieve the objectives of the Commission’s focus on disclosure effectiveness.

    31 July 2015

    Comment Letter - FASB proposal to simplify equity method accounting
    In our comment letter, we supported the FASB’s objective in its simplification initiative. We agreed that the proposed amendments would simplify the initial recognition and measurement of equity method investments. However, we have concerns about the proposal to eliminate the identification of and accounting for basis differences and question whether it meets the FASB’s objective of simplifying US GAAP and, more broadly, whether the project would be better dealt with as part of a holistic review of the equity method. Consequently, we suggested, at a minimum, that the Board perform broader outreach prior to moving forward. However, we supported eliminating the requirement that an equity method investor account for an equity method investment retroactively when the investment initially qualifies for the equity method.

    31 July 2015

    Comment Letter - PCAOB staff consultation paper on the auditor’s use of the work of specialists
    In our comment letter, we support the PCAOB's efforts to evaluate whether existing standards on the auditor's use of the work of specialists can and should be improved. However, we suggest alternatives to several proposals outlined in the PCAOB staff's Consultation Paper, including extending the supervision requirements in AS 10 to all arrangements involving an auditor's engaged specialist and requiring the work of an auditor's specialist to be evaluated differently depending on whether the specialist develops an independent estimate or tests the methods and significant assumptions used by the company. We also suggest alternatives to evaluating the objectivity of an auditor's specialist either through (1) requiring an auditor's engaged specialist to comply with the requirements of Rule 2-01 of Regulation S-X adopted by the SEC or (2) requiring the auditor to apply a "reasonable investor test" as part of the enhanced objectivity approach.

    2 July 2015

    Comment Letter - FASB proposal on measurement-period simplification
    In our comment letter, we supported the proposal to eliminate the requirement that an acquirer in a business combination account for measurement-period adjustments retrospectively. We said the proposal would reduce costs and complexity while continuing to provide users of the financial statements with high-quality information.

    30 June 2015

    Comment Letter - FASB proposal to clarify the guidance in the new revenue standard for performance obligations and licenses of IP
    In our comment letter, we supported the FASB’s proposal to clarify the guidance in its new revenue standard on identifying performance obligations and accounting for licenses of intellectual property (IP) and provide examples to reduce diversity in practice. Overall, we believe that the proposed clarifications would result in more consistent application and, in many cases, provide a practical approach to applying the standard. We also recommended additional clarifications.

    29 May 2015

    Comment letter - FASB’s proposal to defer the effective date of the new revenue recognition standard
    In our comment letter, we supported the FASB’s proposal to defer the effective date of the new standard by one year and to allow entities to early adopt the standard as of the original public entity effective date.

    29 May 2015

    Comment Letter - FASB proposal on balance sheet classification of deferred taxes
    In our comment letter, we supported the proposal to eliminate the requirement to classify deferred tax assets or liabilities or any related valuation allowance as current or noncurrent. We also believe the proposal would not significantly affect the quality of information provided to financial statement users.

    29 May 2015

    Comment Letter - FASB proposal on income tax accounting for intercompany sales or transfers
    In our comment letter, we supported the Board’s proposal to eliminate today’s requirement that companies defer the income tax effects of sales or transfers of assets among members of a consolidated group and instead require them to immediately recognize these effects in the income statement. Our support is based principally on the issues and errors we have seen related to the scope and application of today’s requirement, which is an exception to the income tax accounting guidance. However, we note that many preparers have dedicated considerable resources to establishing accounting policies, systems, processes and controls to address today’s accounting. We also acknowledge that the proposal would not eliminate complexity.

    11 May 2015

    Comment Letter - Three-year review of the private company council
    In our comment letter, we reconfirmed our support for providing relief to private companies under US GAAP. We also encouraged the PCC to work closely with the FASB on its projects to simplify accounting for all entities because decreasing complexity for all entities may reduce the need for private company alternatives.

    28 April 2015

    Comment Letter - FASB proposal to provide disclosures about hybrid financial instruments with bifurcated embedded derivatives
    In our comment letter, we supported the Board’s efforts to enhance the transparency and usefulness of information provided to financial statement users. However, we raised concerns about the ability of the proposed disclosure to meet the Board’s objective of providing information on the overall economics and cash flows of these instruments.

    17 February 2015

    Comment Letter - FASB proposal to increase transparency about an investment company’s investments in other investment companies
    In our comment letter, we supported the Board’s efforts to increase transparency about an investment company’s investments in other investment companies by improving the existing disclosure requirements under Accounting Standards Codification 946, Financial Services - Investment Companies. However, we raised concerns about the operability and auditability of the proposed amendments.

    22 January 2015

    Comment Letter - AICPA’s proposed statement on standards for attestation agreements
    In our comment letter on the Proposed Statement on Standards for Attestation Engagements, Reporting on an Examination of Controls at a Service Organization Relevant to User Entities’ Internal Control Over Financial Reporting: Clarification and Recodification, we supported clarifying the standards in accordance with the clarity drafting conventions used in the proposed general attestation standard.

    15 December 2014

    Comment Letter - FASB proposal to simplify the presentation of debt issuance costs
    In our comment letter, we supported the FASB's proposed requirement that debt issuance costs be presented in the balance sheet as a direct deduction from the carrying amount of the debt liability, consistent with debt discounts or premiums. The proposal would eliminate the inconsistency between today’s presentation requirement for debt issuance costs and the Conceptual Framework. We also highlight matters related to third-party debt issuance costs where we believe the FASB can do more to address complexity.

    10 December 2014

    Comment letter - AICPA's Proposed Statement on Auditing Standard, An Audit of Internal Control Over Financial Reporting That Is Integrated With An Audit of Financial Statements
    In our comment letter, we agree with the Auditing Standards Board’s proposal to move the content of AT section 501, An Examination of an Entity’s Internal Control Over Financial Reporting That Is Integrated With An Audit Of Its Financial Statements, from the attestation standards into generally accepted auditing standards. Further, we support the development of an attestation standard to address examinations of internal control that aren’t integrated with audits of financial statements.

    9 December 2014

    Comment letter – FASB proposal to simplify the measurement date of an employer’s defined benefit obligation and plan assets
    In our comment letter, we supported the FASB's effort to address the cost and complexity for employers with fiscal year ends that do not fall on the end of a calendar month by providing a practical expedient to measure their defined benefit obligations and plan assets as of the end of the month closest to their fiscal year ends. We also recommended that the Board provide the same practical expedient for employee benefit plans.

    26 November 2014

    Comment Letter - Technical corrections and improvements
    In our comment letter on the Proposed Accounting Standards Update, Technical Corrections and Improvements, we agree that for the most part, the proposed changes would clarify the Codification, correct unintended application of guidance or make minor improvements to the Codification that would not be expected to have a significant effect on current accounting practice or create a significant administrative cost to most entities. However, we express concern about certain of the proposed amendments.

    3 November 2014

    Comment Letter - PCAOB staff consultation paper: auditing accounting estimates and fair value measurements
    In our comment letter, we said we support the PCAOB’s efforts to evaluate whether existing standards on auditing accounting estimates and fair value measurements can and should be improved. However, we raise concerns and offer alternatives to several of the proposals outlined in the PCAOB staff’s Consultation Paper, including the adoption of a single standard, management’s use of a specialist, evaluating the reasonableness of an accounting estimate or fair value measurement and the use of third-party pricing services.

    30 September 2014

    Comment Letter - FASB proposal to eliminate the concept of extraordinary items
    In our comment letter, we supported the FASB's efforts to reduce the cost and complexity of financial reporting by eliminating the concept of extraordinary items. We believe the proposal would not affect the quality of information provided to financial statement users.

    30 September 2014

    Comment Letter - FASB proposal to simplify the measurement of inventory
    In our comment letter, we said we do not support the FASB’s proposal to measure inventory at the lower of cost or net realizable value (LCNRV). For entities that use the last-in, first-out (LIFO) accounting method in declining price environments, we believe the Proposed Standard could increase the cost and complexity of preparing the financial statements and, in certain circumstances, reduce the usefulness of the information provided to users. We also said the continuing acceptability of the retail inventory method should be made more clear in a final standard.

    14 July 2014

    Comment Letter - Chapter 8: Notes to financial statements
    In our comment letter, we supported the FASB’s objective of improving disclosure effectiveness in the notes to the financial statements by developing a framework the Board would apply when creating new disclosure requirements and evaluating existing ones. However, we are concerned that the proposed framework would actually perpetuate the significant expansion in disclosure that has occurred over the past few decades. We suggest changes to the framework, including the testing process, and recommend that the Board provide guidance on materiality and clearly distinguish between annual and interim requirements.

    23 June 2014

    Comment Letter - AICPA’s proposed statement on standards for attestation engagements
    In our comment letter on the Proposed Statement on Standards for Attestation Engagements, Subject-Matter Specific Attestation Standards: Clarification and Recodification, we supported clarifying the standards in accordance with the clarity drafting conventions used in the proposed general attestation standard.

    24 March 2014

    Comment Letter - SEC 'Regulation A+' proposal
    In our comment letter on the SECs proposed amendments to allow exempt public offerings under Regulation A of up to $50 million in a 12-month period, we recommend that the SEC consider additional opportunities to leverage disclosure requirements in existing SEC rules and regulations for registered offerings and scale those requirements for unregistered offerings conducted under Regulation A. We also encourage the SEC to clarify certain terminology and disclosure requirements in the proposal that could be difficult to interpret or apply.

    12 February 2014

    Comment Letter - Improving the transparency of audits
    In our comment letter, we support identifying certain non-signing firms that have a significant role in an audit but do not support identifying the engagement partner in either the audit report or a public filing with the PCAOB because we don’t believe this would provide meaningful information to investors.

    3 February 2014

    Comment Letter - Crowdfunding
    In our comment letter, we recommended that the SEC reconsider the financial reporting requirements it proposed for issuers that use a new crowdfunding exemption to raise up to $1 million a year by selling shares to investors over the internet. We said that the costs to comply with the proposed requirements in a crowdfunding offering and ongoing annual reporting would likely discourage use of the crowdfunding exemption, which was mandated by the Jumpstart Our Business Startups Act.

    13 January 2014

    Comment Letter - FASB proposal to eliminate development stage entity guidance
    In our comment letter, we said we supported the FASB's efforts to reduce financial reporting cost and complexity by eliminating ASC 915 and its additional reporting requirements for development stage entities. However, we expressed our concern about how the proposed amendments could affect the way in which companies apply ASC 810's variable interest entity guidance and ASC 805's definition of a business when evaluating certain entities or operations that are in a development stage.

    18 December 2013

    Comment Letter - Proposed auditing standards on the auditor's report and the auditor's responsibilities regarding other information and related amendments
    In our comment letter, we supported the PCAOB's effort to enhance the auditor’s report. However, we believe that certain elements of the proposal may be difficult to apply in practice. We also expressed concerns that the proposed requirements for other information would significantly expand the auditor’s performance responsibilities and result in increased liability risks for audit firms. In addition, while we support more transparency about auditor tenure, we believe that these disclosures can be made outside the auditor’s report. We recommended changes to the proposal to address these concerns.

    2 December 2013

    Comment Letter - Pay ratio disclosure
    In our comment letter, we focus on certain aspects of the proposal, including sampling methods and pay ratio computation. We also make recommendations that we believe would reduce the cost and burden on issuers, promote disclosure and enhance comparability. The proposal would require most issuers to disclose the median annual compensation of all of their employees (excluding the principal executive officer) and the ratio of that amount to the annual compensation of their principal executive officer.

    29 November 2013

    Comment Letter - Statement on standards for attestation engagements
    In our comment letter, we supported the AICPA’s objective of addressing concerns about the clarity, length and complexity of the attestation standards. Additionally, we commented on several ways to increase consistency between examinations and audit engagements.

    30 October 2013

    Comment Letter - SEC reproposal on credit risk retention
    In our comment letter to the SEC on the credit risk retention reproposal it issued jointly with other agencies, we focus on the consolidation accounting ramifications. The proposal would require sponsors of certain asset-backed securitizations to retain at least 5% of the credit risk. The rule was mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

    28 October 2013

    Comment Letter - FASB proposed ASU on insurance contracts
    In our comment letter, we encouraged the FASB and the IASB to work together to make their proposals more comparable. We also said the FASB needs to address certain issues before finalizing the guidance. Our most significant concerns relate to the proposed scope, discount rates and how changes in these rates would be recognized, recognition of changes in expected cash flows, revenue recognition, presentation and transition. We also encourage the Board to consider simplifying certain areas of the proposal to make it less costly to apply.

    14 October 2013

    Comment Letter - PCC proposal on applying variable interest entity guidance to common control leasing arrangements
    In our comment letter, we said the Private Company Council’s proposal to permit private companies to avoid applying the variable interest entity (VIE) guidance to common control leasing arrangements when certain criteria are met would achieve the desired result of excluding the effects of a lessor’s financial position and operating results from a lessee’s financial statements. However, our experience suggests that the same objective may be achieved by clarifying the example in the Codification on the application of the VIE model.

    24 September 2013

    Comment Letter - FASB proposal on going concern uncertainties
    In our comment letter, we said we support the FASB's effort to develop a going concern model that would require preparers of financial statements to assess going concern uncertainties and provide more timely footnote disclosures. However, we said certain issues need to be addressed before any final guidance on the subject is published.

    13 September 2013

    Comment Letter - FASB/IASB proposal on leasing
    While we continue to support the Boards’ efforts to improve the accounting for leases to provide greater transparency in financial reporting and address the needs of users of financial statements, we do not support the Proposal. We are unable to support the Proposal because it is unclear to us whether the ED would significantly improve the decision-useful information available to financial statement users. It also is unclear to us whether any of the perceived benefits to financial statement users would justify the costs and complexity of applying the ED.

    25 July 2013

    Comment Letter - Technical corrections and improvements related to glossary terms
    Our comment letter highlights proposed changes to ASC glossary terms that could have significant effects on existing practice, may have unintended consequences and/or may be unclear to stakeholders.

    8 July 2013

    Comment letter - PCAOB reproposal on related party transactions
    In our comment letter, we express our support for the reproposal. We have one concern with the reproposal regarding the proposed effective date. The Board proposes that the reproposal would be effective, subject to approval by the Securities and Exchange Commission (SEC), for audits of financial statements for fiscal years beginning on or after 15 December 2013. We believe that this effective date is operational only if the SEC approves the reproposal before 31 October 2013.

    31 May 2013

    Comment letter - FASB proposal on credit losses of financial instruments 
    In our comment letter, we urge the FASB to work with the IASB to converge their proposals to require more timely recognition of credit losses than under today’s incurred loss model. We note that the FASB could accomplish its goal of timelier recognition of losses by lowering the threshold for recognizing losses. We also recommend that the FASB exclude debt securities and trade, lease and reinsurance receivables from its proposal.

    28 May 2013

    Comment letter - PCAOB’s proposed framework for reorganizing its auditing standards
    In our comment letter, we say that we do not support the proposed reorganization at this time. While we agree that reorganizing the standards may help users navigate them more easily, we disagree with the PCAOB’s assertion that the proposed reorganization would help avoid confusion between the PCAOB’s standards and the recently reorganized standards of the ASB or that the proposed structure would facilitate comparison of PCAOB and IAASB standards.

    15 May 2013

    Comment letter - FASB proposal on classification and measurement of financial instruments
    In our comment letter, we say that while the FASB proposal on classification and measurement of financial instruments would represent a big step toward convergence, we do not support finalizing it in its current form. We believe the proposal may inappropriately require too many financial instruments, including certain common debt instruments, to be measured at fair value with changes in fair value recognized in net income. We are also concerned that certain provisions of the proposal could be interpreted in different ways and lead to diversity in practice. However, we believe the FASB can make specific changes and clarifications that will improve the proposal’s operability.

    22 January 2013

    Comment letter - FASB proposal to clarify the scope of a fair value disclosure for nonpublic entities
    We agreed with the FASB’s proposal to amend ASC 825 to clarify that nonpublic entities are not required to disclose the fair value hierarchy level for items that are not measured at fair value on the statement of financial position but for which fair value is disclosed. We also recommended that the FASB subsequently address the overlap in ASC 825 and ASC 820 regarding this disclosure requirement as well as situations where terms such as “nonpublic entity” have multiple definitions in the glossary of the Codification.

    17 January 2013

    Comment letter - COSO’s revised internal control framework and compendium of approaches and examples
    We support COSO’s efforts to update its 1992 Internal Control – Integrated Framework to reflect changes in the business and operating environment and believe the Compendium will provide users with helpful guidance. In our comment letter, we expressed our support for COSO’s efforts to update and enhance the framework to enable users to better develop, implement and monitor systems of internal control. We also expressed certain concerns and suggested modifications to the revised framework and compendium, including, among others, enhancing the guidance related to an organization’s assessment of the effectiveness of its internal controls; modifying its definitions of deficiencies and major deficiencies; providing guidance about the precision of management review controls; and providing additional guidance on the application of the Revised Framework to smaller organizations.

    14 January 2013

    Comment letter - CFTC proposal on enhancing customer protection
    In our comment letter on the CFTC’s proposal, Enhanced Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and Derivatives Clearing Organizations, we questioned the need for a requirement that auditors of FCMs be registered with and have undergone an examination by the PCAOB. We also said the proposal that deficiencies noted in such an examination must have been remediated to the satisfaction of the PCAOB within three years of a report would be unworkable. Instead, we recommended that the CFTC consider seeking statutory change to make auditors of FCMs subject to the registration and inspection requirements of the PCAOB or require that auditors of FCMs be registered with and subject to inspection by the PCAOB, similar to the requirement for auditors performing surprise examinations of investment advisers under the SEC's Custody Rule.

    11 September 2012

    Comment Letter - Section 108 of the JOBS Act - Regulation S-K Review
    Our comment letter recommends that the SEC broaden the scope of its review and eliminate redundant or outdated disclosures for all issuers. We also suggest that informational disclosures that are not specific to a reporting period should appear in a company profile and that only new information should be included in periodic reports.

    31 May 2012

    Comment Letter - Proposed PCAOB auditing standard on related parties
    Our comment letter supports the Board’s efforts to update the requirements of AU Section 334, Related Parties, and adopt other proposed amendments. We believe these actions have the potential to improve audit quality. However, we have some concerns with certain aspects of the proposal that are addressed in our letter.

    30 March 2012

    Comment Letter - Exposure draft of Internal Control - Integrated Framework
    Our comment letter supports the Committee of Sponsoring Organization’s efforts to help organizations effectively and efficiently develop and maintain systems of internal control by enhancing the 1992 framework to reflect changes in the business and operating environment since its development. We also outline our concerns about the proposal and suggest modifications to clarify a number of areas in the proposed framework and to make it more helpful to users.

    29 February 2012

    Comment Letter - PCAOB proposal on communications with audit committees
    Our letter supports the PCAOB's efforts to enhance communication with audit committees and provide additional information to help audit committees fulfill their oversight responsibilities. We believe the proposal will help enhance audit quality. Our comment letter also offers suggestions to improve the final standard.

    18 November 2011

    Comment letter - PCAOB concept release on auditor independence and audit firm rotation
    In our letter, we affirm our view that auditor independence, objectivity and professional skepticism are of paramount importance, but state that we do not believe mandatory audit firm rotation would improve audit quality or auditor skepticism. In fact, we believe it would harm corporate governance, investor interests and the objective of maintaining a robust, highly skilled independent accounting profession performing high-quality audits. In addition, we outline our ideas on measures that should be considered by the PCAOB to achieve its objectives and our views on other ideas presented in the concept release.

    18 November 2011

    Summary of key messages - PCAOB concept release on auditor independence and mandatory firm rotation
    This document provides a summary of Ernst & Young's key messages to the PCAOB as expressed in our comment letter on the concept release on auditor independence and audit firm rotation.

    30 September 2011

    Comment Letter - Concept release on possible revisions to PCAOB standards related to reports on audited financial statements
    Our comment letter to the PCAOB supports responsible change to the auditor reporting model and outlines a possible approach to revising the auditor’s reporting model.

    28 July 2011

    Comment Letter - Workplan for incorporating IFRS into the financial reporting system for US issuers
    Our comment letter to the SEC supports the approach described in the Staff Paper. We believe that it is a thoughtful and balanced way of moving closer to achieving the ultimate goal of a single set of high-quality globally accepted accounting standards.

    1 June 2011

    Comment Letter - Financial statements prepared in accordance with a financial reporting framework generally accepted in another country
    Our comment letter supports the issuance of the proposed revised SAS, and we agree with the ASB’s decisions to change the guidance from the previous exposure draft.

    29 April 2011

    Comment Letter - Clearing agency standards for operation and governance
    Our comment letter supports the SEC proposal to allow a non-US- based clearing agency to post on its website audited financial statements prepared in accordance with either US GAAP or IFRS as issued by the IASB, without reconciliation to US GAAP.

    27 April 2011

    Comment Letter - Balance sheet offsetting
    Our comment letter recommends that the Boards should consider adopting a model that retains the existing exceptions in US GAAP for repo and reverse repo agreements and certain derivative contracts subject to master netting arrangements. We believe that adoption of the US GAAP exceptions would be a pragmatic solution to achieve convergence in offsetting.

    25 April 2011

    Comment Letter - Selected issues about hedge accounting
    Ernst & Young is supportive of the Boards' efforts to arrive at a converged solution to accounting for hedging transactions. On balance, we support the overall direction of the IASB’s proposal to align hedge accounting with an entity’s risk management activities.

    21 April 2011

    Comment Letter - Alert as to the intended use of the auditor's written communication
    Our comment letter supports the issuance of this proposed SAS and we continue to support the redrafting of the SASs to apply the ASB’s clarity drafting conventions and to converge with International Standards on Auditing (ISAs).

    31 January 2011

    Comment Letter - FASB’s discussion paper, effective dates and transition methods
    Our comment letter suggests that the FASB further delay the effective date of the various joint projects because preparers will need a good deal of time to make the necessary changes prior to adoption.

    14 January 2011

    Comment Letter - Reconsideration of effective control for repurchase agreements
    Our comment letter supports the FASB's proposal to amend the accounting model for repurchase agreements and similar arrangements that both entitle and obligate the transferor to repurchase financial assets before their maturity. We believe the proposed amendments represent an improvement and simplification to the accounting for these arrangements.

    3 January 2011

    Comment Letter - Letters for underwriters and certain other requesting parties (Redrafted)
    Our comment letter supports the issuance of the proposed SAS and the redrafting of the proposed SAS to apply the ASB’s clarity drafting conventions.

    10 December 2010

    Comment Letter - Standard setting timetable for MoU projects
    This comment letter provides our views on the pace of accounting changes resulting from the joint projects.

    9 December 2010

    Comment Letter - Standard setting timetable for MoU projects
    Our comment letter expresses Ernst & Young's views on effective dates of the FASB and IASB joint projects.

    1 December 2010

    Comment letter - Short-term borrowings disclosure
    Our comment letter supports the Commission’s proposed alignment of the definition of “short-term borrowings” for purposes of both MD&A and Form 8-K Items 2.03 and 2.04.

    15 November 2010

    Comment Letter - Interim financial information (Redrafted)
    Our comment letter supports the issuance of the proposed SAS and the redrafting of the proposed SAS to apply the ASB’s clarity drafting conventions.

    15 November 2010

    Comment Letter - Issuer review of assets in offerings of asset-backed securities
    Our comment letter discusses the nature of procedures that accountants have historically performed related to ABS offerings. Analysis has shown that investors, as well as underwriters and issuers, in many cases did not adequately understand the risks of the assets underlying the ABS. We believe that Sections 945 and 932 of the Dodd-Frank Wall Street Reform Act were intended to mitigate these shortcomings by enhancing the understanding of the assets underlying the ABS.

    12 November 2010

    Comment Letter - Application of the “failure to supervise” provision of the Sarbanes-Oxley Act of 2002
    Our comment letter provides our views on the PCAOB Concept Release with regard to sanctions on registered public accounting firms for failing reasonably to supervise.

    13 September 2010

    Comment Letter - PCAOB proposed auditing standard–confirmation
    Our comment letter provides our views on the PCAOB's proposed rule on audit confirmations.

    10 September 2010

    Comment Letter - Financial instruments and derivative/hedging activities
    This comment letter provides our views on the FASB's proposal on the accounting for financial instruments and derivative instruments and hedging activities.

    10 August 2010

    Comment Letter - Disclosure of Certain Loss Contingencies
    This comment letter requests an extension of comment letter due date for the FASB's re-proposal on contingencies.

    2 August 2010

    Comment letter - Asset-backed securities
    Our comment letter provides our views on the third party review of repurchase obligations, accounting issues arising with the risk retention mandate, financial information regarding parties obligated to repurchase assets and servicer assessment of compliance with servicing criteria.

    10 March 2010

    Comment Letter - Reporting on compliance with aspects of contractual agreements or regulatory requirements in connection with audited financial statements (Redrafted)
    Our comment letter supports the issuance of the proposed SAS and continue to support the redrafting of the SASs to apply the ASB’s clarity drafting conventions and to converge with International Standards on Auditing (ISAs).

    1 March 2010

    Comment Letter - PCAOB Reproposed Risk Assessment Standards
    This comment letter provides our views on the PCAOB's proposed risk assessment standards.

    27 January 2010

    Comment Letter - Proposed ASU on subsequent events
    This comment letter provides our views on the FASB's proposal on subsequent events.

    24 November 2009

    Comment Letter - Proposed Rules on Auditing Standard No. 7, Engagement Quality Review
    This comment letter provides our views on the PCAOB's re-proposal on engagement quality review.

    11 November 2009

    Comment Letter - Proposed ASU, "Derivatives and Hedging (Topic 815)– Scope Exception Related to Embedded Credit Derivatives"
    This comment letter provides our views on FASB's proposal on embedded credit derivatives and scope exception.

    14 October 2009

    Comment Letter - Proposed ASU: Oil and gas reserve estimation and disclosure
    This comment letter provides our views on the FASB's proposal to improve oil and gas reserve estimation disclosures.

    16 September 2009

    Comment Letter - SEC’s proposed proxy disclosures
    This comment letters expresses our views on the SEC's proposal to improve proxies.

    24 August 2009

    Comment Letter - FASB Exposure Draft on disclosures about the credit quality of financing receivables and the allowance for credit losses
    This comment letter provides our views on the FASB proposal on the allowance for credit losses and the credit quality of financing receivables.

    19 June 2009

    Comment Letter - Preliminary views on revenue recognition in contracts with customers
    This comment letter provides our views on the IASB/FASB Preliminary Views on revenue recognition.

    12 June 2009

    Comment Letter - FASB Staff Position FIN 48-d: Application guidance for pass-through entities
    This comment letter provides our views on a proposed FSP on FIN 48 application guidance.

    5 June 2009

    Comment Letter - Concept release on possible revisions to the PCAOB’s standard on audit confirmations
    This comment letter provides our views on PCAOB's Concept Release on audit confirmations.

    15 May 2009

    Comment Letter - FASB proposal related to various technical corrections
    This comment letter provides our views on certain technical corrections proposed by the FASB.

    15 April 2009

    Comment Letter - PCAOB proposed auditing standard on engagement quality reviews
    This comment letter provides our views on the PCAOB's revised proposal on engagement quality reviews.

    4 March 2009

    Comment Letter - SEC proposed Roadmap for the potential use of IFRS by US registrants
    Our comment letter provides Ernst & Young's views on the potential adoption of IFRS by US registrants.

    18 February 2009

    Comment Letter - Proposed PCAOB Auditing Standards: Auditor's assessment of and response to risk
    This comment letter provides our views on the proposed PCAOB proposal on risk assessment.

    13 February 2009

    Comment Letter - Proposed Statement 133 Implementation Issue No. C22: Scope exception for embedded credit derivative
    The comment letter provides our views on DIG Issue C 22 on embedded credit derivatives.

    13 January 2009

    Comment Letter - Proposed FSP FAS 141(R)-a-Preacquisition contingencies in business combinations
    This comment letter presents our views on the proposed FASB FSP on pre-acquisition contingencies in business combinations.

    6 January 2009

    Comment Letter - Proposed Accounting Standards Update, "Amendments to Statement 167 for Certain Investment Funds"
    This comment letter provides our views on the FASB's proposal to defer FAS 167 for certain entities.

    5 December 2008

    Comment Letter - FASB and IASB Exposure Drafts on earnings per share
    This comment letter provides our views of both the FASB and IASB proposals on the calculation of earnings per share.

    30 October 2008

    Comment Letter - Proposed Amendment to FIN 46(R) - Consolidation of variable interest entities
    This comment letter provides our views on the FASB's proposed amendment to FIN 46(R) on consolidation of variable interest entities.

    3 October 2008

    Comment Letter - IASB/FASB Joint Conceptual Framework Project - DP/ITC on Reducing Complexity in Reporting Financial Instruments
    This comment letter provides our views on the joint IASB/FASB Discussion paper on reducing complexity in financial instruments.

    3 September 2008

    Comment Letter - SEC proposal on modernization of oil and gas reporting requirements
    This comment letter provides our views on the SEC's proposal to modernize oil and gas reporting requirements.

    19 August 2008

    Comment Letter - FASB Exposure Draft on Hedging
    This comment letter provides our views on the FASB's proposal on hedging activities.

    14 August 2008

    Comment Letter - COSO guidance on monitoring internal control systems
    This comment letter provides our views on the Committee of Sponsoring Organizations (COSO) guidance on monitoring internal control systems.

    31 July 2008

    Comment Letter - SEC proposed rule on XBRL
    This comment letter provides our views on the SEC's proposal to modernize oil and gas reporting requirements.

    10 July 2008

    Comment Letter - FASB Request for Additional Comments NFP: M&A
    This comment letter provides our views on the FASB's proposal on mergers and acquisition of not-for-profit entities.

    30 June 2008

    Comment Letter - Proposed FSP FAS 133-b and FIN 45-c on disclosures about credit derivatives
    This comment letter provides our views on the FASB's proposed FSP on disclosures about credit derivatives.

    27 June 2008

    Comment Letter - Recommendations of the Treasury Advisory Committee on the accounting and auditing profession
    This comment letter provides our views on the Treasury Advisory Committee on the accounting and auditing profession.

    30 May 2008

    Comment Letter - FASB preliminary views: Financial instruments with characteristics of equity
    Our comment letter supports a joint FASB and IASB project to comprehensively consider the model for distinguishing between liabilities and equity as well as the related measurement and financial statement presentation issues. We tentatively support the “basic ownership” approach from the three models described in the PV for various reasons, including its perceived simplicity.

    12 May 2008

    Comment Letter - PCAOB Proposal on Engagement Quality Review
    This comment letter provides our views on the PCAOB's proposal on engagement quality review.

    5 May 2008

    Comment Letter - EITF07-05 Draft Abstract-Determining whether an instrument (or embedded feature) is indexed to an entity's own stock
    This comment letter provides our views on whether an instrument (or embedded feature) is indexed to an entity's own stock.

    2 May 2008

    Comment Letter - FASB Proposed FSP FAS 117-a-NFP endowments
    This comment letter provides our views on the FASB's proposed FSP on endowments held by not-for-profits.

    2 May 2008

    Comment Letter - FASB Proposed FSP FAS 132R-a-pension disclosure matters
    This comment letter provides our views on the FASB proposed FSP on pension disclosure matters.

    31 March 2008

    Comment Letter - Recommendations of SEC Advisory Committee on improvements to financial reporting
    Recommendations of SEC Advisory Committee on improvements to financial reporting.

    13 March 2008

    Comment Letter - Proposed FSP SOP 90-7-a, An Amendment of AICPA Statement of Position 90-7
    This comment letter provides our views on the proposed amendment of AICPA Statement of Position 90-7. This Sop related to entities undergoing reorganization or bankruptcy.

    10 March 2008

    Comment Letter - SEC proposal relating to internal control reporting for non-accelerated Filers
    Focuses on SEC proposal relating to internal control reporting for non-accelerated filers.

    10 February 2008

    Comment Letter - Proposed changes to structure of the FASB
    This comment letter provides our views on the Financial Accounting Federation's proposal to change the structure of the FASB and GASB.

    18 January 2008

    Comment Letter - Proposed FASB Staff Position No. FIN 48-b-effective date of FIN 48 for Nonpublic Enterprises
    This comment letter provides our views about the effective date of FIN 48 for nonpublic companies.